Can a plan change COBRA premium requirements during the extension period?

• A. No changes allowed
• B. Premiums may change if the plan changes for all similarly situated enrollees, subject to 102% cap
• C. Premiums may double at will
• D. Premiums must be identical for all beneficiaries

Answer: (B)

The key idea is that COBRA premiums track the plan’s actual cost and can adjust during the extension period if the plan changes the cost for all similarly situated enrollees. The amount you can charge isn’t unlimited—the law imposes a 102% cap, meaning you may bill up to 102% of the plan’s cost for that coverage (the 2% admin fee is allowed). So if the plan increases premiums for everyone in the same category, COBRA participants can see a corresponding increase, but never beyond that 102% limit. This makes premium changes fair and predictable across the group, including during any extension period.

Why the other ideas don’t fit: premiums aren’t fixed with no changes allowed, nor can they be doubled at will due to the 102% cap. And while premiums should apply uniformly to similarly situated enrollees, they aren’t required to be identical for every beneficiary in every situation—they reflect changes in the plan’s cost that affect that same group.